# Opposition Brief — District 2, United Mine Workers of America v. Helen Mining Co. > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385018_0847%3A2 ## Record - **Collection:** Supreme Court brief - **Document type:** Opposition Brief - **Published:** January 1, 1985 - **Citation:** 474 U.S. 1006 ## Text —_ | Supreme Court, U.S. | FILED Noy 2 #6 JOSEPH F. SPANIOL, Jt No. 85-585 CLERK Lat \S \ IN THE Supreme Court of the United States October Term, 1985 DISTRICT 2, UNITED MINE WORKERS OF AMERICA, GEORGE ZAYAC and JANET ZAYAC, . Petitioners THE HELEN MINING COMPANY, neal Respondent HARRISON COMBS, JOHN J. O’CONNELL and PAUL R. DEAN, as Trustees of the UNITED MINE WORKERS OF AMERICA HEALTH AND RETIREMENT FUNDS BRIEF IN OPPOSITION TO PETITION FOR WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ANTHONY J. POLITO Counsel of Record RONALD S. CUSANO CORCORAN, HARDESTY, WHYTE & POLITO, P.C. Suite 210, Two Chatham Center Pittsburgh, Pennsylvania 15219 (412) 391-2740 Counsel for Respondent November 1, 1985 HERBICK & HELI) PRINTING COMPINS, PITTSBURGH, PA. 14233 BEST AVAILABLE COPY © QUESTION PRESENTED Whether the Court of Appeals properly held that the enforcement by the Trustees of an eligibility require- ment for health benefits which was established through collective bargaining could not be set aside by a court unless such action violated federal law or policy. TABLE OF CONTENTS PAGE QUESTION PR ete 6 iiWi hcl as ceva pncics i TABLE OF AUERRGRSeMe Asc bin seb aseees senwa' iii DISCLOSURE OF CORPORATE AFFILIATIONS AND FINANCIAL INTEREST ................... iv STATEMENT OF Tats CAM ccc cece seccetescnce 1 I, Procedural Bagge cunt che cates oh en eens 1 TT. Factual BM ~6kcns haa ado su shen wn 3 REASONS FOR DENYING THE WRIT ........... 7 I. SUMMARY OF ARGUMENT ................ 7 II. ENFORCEMENT OF COLLECTIVELY-BAR- GAINED PROVISIONS IN A HEALTH OR PENSION PLAN IS NOT SUBJECT TO RE- Nie ON A STANDARD OF REASONABLE- . 1. Robinson should not be narrowly construed 10 2. Petitioners are really challenging the eligi- bility requirement itself .................. 13 3. The prior approval requirement was the re- sult of collective bargaining .............. 14 4. Claimants’ protection lies in the collective bargaining PROQGHID as 05 ck vscuk seeker en’ 15 III. THE CIRCUIT COURT’S DECISION IN THIS CASE IS NOT IN CONFLICT WITH THE DECI- SIONS OF OTHER COURTS OF APPEALS ... 15 CONCLUSION |. ... «+050 saab eee eee ee 16 ii Sai aoe Table of Authorities. TABLE OF AUTHORITIES Cases PAGE Moore v. Reynolds Metals Co. Retirement Program, po GE | re 11,12 Sellers v. O’Connell, 701 F.2d 575 (6th Cir. 1983) . 11, 12 United Mine Workers of America Health and Retire- ment Funds v. Robinson, 455 U.S. 562, 102 S.Ct. Rae Ch Meme GED CRUE) occ cc ccc scene passim STATUTES Employee Retirement Income Security Act Re OE sso bcs e cee sees evasesen's 2 Labor Management Relations Act ee 2 ME ov Vs ae scan esdwsceecsees 9 iii DISCLOSURE OF CORPORATE AFFILIATIONS AND FINANCIAL INTEREST Respondent, The Helen Mining Company, is a wholly owned subsidiary of The Valley Camp Coal Company. Quaker State Oil Refining Corporation is the parent cor- poration of The Valley Camp Coal Company. Other wholly owned subsidiaries of The Valley Camp Coal Com- pany and affiliates of The Helen Mining Company include Donaldson Mine Company, Shrewsbury Coal Company, Elm Grove Coal Company, Valley Camp of Utah, Inc., Kanawha and Hocking Coal & Coke Company, Kelley’s Creek and Northwestern Railroad Company, Great Lakes Coal and Dock Company, and Pennsylvania and West Virginia Supply Corporation. iv No. 85-585 IN THE Supreme Court of the United States October Term, 1985 DISTRICT 2, UNITED MINE WORKERS OF AMERICA, GEORGE ZAYAC and JANET ZAYAC, . Petitioners THE HELEN MINING COMPANY, ond Respondent HARRISON COMBS, JOHN J. O’CONNELL and PAUL R. DEAN, as Trustees of the UNITED MINE WORKERS OF AMERICA HEALTH AND RETIREMENT FUNDS BRIEF IN OPPOSITION TO PETITION FOR WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT STATEMENT OF THE CASE I. Procedural History On November 1, 1983, the Trustees of the United Mine Workers of America Health and Retirement Funds (““Trustees’’) issued a written decision upholding the de- nial by The Helen Mining Company (“Helen”) of a claim of petitioners, George and Janet Zayac, for certain medi- cal benefits under the Employee Benefit Plan maintained by Helen for its classified employees pursuant to the provisions of Article XX, Section (c)(3)(i) of the National Statement of the Case. Bituminous Coal Wage Agreement of 1981 (‘1981 Wage Agreement”’). On or about January 16, 1984, petitioners filed a complaint against Helen and the Trustees in the United States District Court for the Western District of Pennsyl- vania (“District Court”) seeking to have the Trustees’ decision set aside and further seeking to have Helen held responsible for the payment of medical costs in the amount of $17,612.30. The complaint asserted jurisdic- tion pursuant to the provisions of Section 301 of the Labor Management Relations Act, 29 U.S.C. § 185 (“LMRA”’), and Section 502 of the Employee Retirement Income Security Act, 29 U.S.C. § 1132 (“ERISA”). On October 9, 1984, after petitioners and respondent Helen had each filed motions for summary judgment, the District Court issued a Memorandum Opinion and Judg- ment Order (App. B) which, inter alia, granted petitioners’ motion, denied Helen’s motion and entered judgment in favor of petitioners and against Helen in the amount of $17,612.30. The Judgment Order also granted the Trustees’ motion to dismiss (App. B). Respondent Helen appealed from the District Court’s decision and on May 31, 1985, thé United States Court of Appeals for the Third Circuit (“Circuit Court”’) issued its Opinion and Order (App. A, C) reversing the District Court and remanding the case with directions to enter summary judgment on behalf of Helen. A Judg- ment Order was then issued by the District Court on June 3, 1985 granting Helen’s motion for summary judg- ment (App. E). Petitioners’ out-of-time petition for rehearing en banc was accepted and then denied by the Circuit Court 2 Statement of the Case. on July 5, 1985 (App. D). This petition for writ of certio- rari then followed. II. Factual Background Petitioners George and Janet Zayac are individuals residing in Indiana County, Pennsylvania. George Zayac was employed by Helen as a classified employee and was, at all relevant times, President of Local 1610, UMWA. Classified employees of Helen are represented for pur- poses of collective bargaining by the UMWA, Interna- tional Union, its geographic division, District 2, UMWA and Local 1610, UMWA. Helen and the UMWA were signatories to the 1981 Wage Agreement, a multi-employer bargaining agree- ment which established the hours, wages and conditions of employment of classified employees of Helen. Pursu- ant to the provisions of Article XX, Section (c)(3)(i) of the 1981 Wage Agreement, Helen had established and maintained a Benefit Plan for its classified e1aployees for the purpose of providing health and other non-pension benefits to eligible participants and their dependents. Prior to 1978, health and other non-pension benefits were provided to classified employees of signatory employers, including Helen, pursuant to the provisions of the 1974 Benefit Plan and Trust, which was adminis- tered by the Trustees, or their predecessors. The Na- tional Bituminous Coal Wage Agreement of 1978 (“1978 Wage Agreement’’) provided for the first time for the establishment and maintenance by the signatory opera- tors of employee benefit plans to provide health and other non-pension benefits to their classified employees. Statement of the Case. In establishing the employee benefit plans to be maintained and implemented by the signatory operators after 1978, the Bituminous Coal Operators Association (“BCOA”), a multi-employer bargaining association of which Helen was a member, and the UMWA negotiators reviewed all of the interpretations that had been estab- lished previously and utilized by the Trustees and, dur- ing the course of bargaining, adopted, revised or rejected those interpretations. What was finally agreed upon in negotiations was then inserted into the United Mine Workers of America 1950 Benefit Plan and Trust, the 1974 Benefit Plan and Trust and the employee benefit plans to be maintained and implemented by the signatory operators. Under the Benefit Plans maintained by Helen and other signatory employers for their classified employees, prior approval by the Plan Administrator was necessary to obtain coverage for certain types of surgical proce- -dures and expenses. The prior approval eligibility re- quirement was among those that were discussed and adopted as a part of the Benefit Plans during and as a result of collective bargaining between the UMWA and BCOA during negotiation of the 1978 Wage Agreement. Moreover, the prior approval requirement was carried forward in the benefit plans maintained by signatory operators, including Helen, under the 1981 Wage Agree- ment. With regard to coverage for the treatment of patho- logical, morbid forms of severe obesity (the condition for which Mrs. Zayac was treated), Article ITI, Sections A(3)(f) and A(11)(a)(25) of the Helen Benefit Plan re- Statement of the Case. quired that all three of the following-canditions be satis- fied to obtain coverage: 1. The beneficiary has a pathological morbid form of severe obesity (two or more times the desira- ble weight); 2. Other more conservative therapies have been tried and proved unsuccessful; and 3. Prior approval has been obtained from the Plan Administrator. Helen’s employees were made aware of the foregoing and other requirements of the Benefit Plan through Sum- mary Plan Descriptions which were distributed to all classified employees by Helen. Such a Summary Plan Description would have been distributed to Mr. Zayac prior to the incident in question. On or about July 8, 1982, Janet Zayac underwent gastric bypass surgery for treatment of a morbid obesity condition. It is undisputed that neither the Zayacs, nor their treating physician, sought or obtained prior ap- proval for said surgery from Helen’s Plan Administrator. Although it is not material to the resolution of the peti- tion, Helen disputes petitioners’ assertion that neither the Zayacs nor thei: treating physician were aware of the prior approval requiremert. On or about September 16, 1982, after the claim for benefits was denied, District 2, UMWA, on behalf of the Zayacs, filed a request for Resolution of Dispute with the Trustees pursuant to Article XX, Section (e)(6) of the 1981 Wage Agreement. Pursuant to that subsection, all disputes arising under the 1981 Wage Agreement with regard t~ »sloyee benefit plans were to be resolved by the Trust« . In addition, Article XX, Section (e)(6) pro- 5 Statement of the Case. vided that the decision of the Trustees “shall be final and binding on the parties.” On November 1, 1983, the Trustees issued a written decision upholding the denial by Helen’s Plan Adminis- trator of the Zayacs’ claim and further holding that Helen was not responsible for the payment of the charges incurred because neither the Zayacs nor their physician had sought or obtained prior approval from the Plan Administrator. Helen does not agree with the comments and responses attributed to Mr. Piccolini and Mr. Hedgepeth, as set forth in the last full paragraph on page 5 and the first paragraph on page 6 of petitioners’ statement of the case. Affidavits were submitted in the District Court ex- plaining and refuting such assertions. However, inas- much as they do not raise factual issues which are mate- rial to the resolution of this petition, Helen will not _comment further at this time. As noted, the District Court set aside the aforemen- tioned decision of the Trustees. Even though it was undisputed that the prior approval requirement was de- rived as a result of collective bargaining, the District Court held that the Trustees’ action was subject to judi- cial review under an arbitrary and capricious standard. The District Court further held that the Trustees’ appli- cation of the prior approval requirement in the instant case was arbitrary and capricious because it frustrated the purpose of that requirement which, according to the District Court, was to insure that benefits were paid only in those instances where it was determined that the sur- gery was medically necessary (App. A, p. 23a). ees Reasons for Denying the Writ. The Circuit Court reversed and, relying on this Court’s decision in United Mine Workers of America Health and Retirements Funds v. Robinson, 455 U:S. 562, 102 S. Ct. 1226, 71 L. Ed. 2d 419 (1982), held as follows: The courts are not free to modify the terms of collec- tively bargained benefit plans nor can the action of trustees taken in enforcing the unambiguous lan- guage of the prior approval requirement of such a benefits plan be termed arbitrary or capricious. (App. A, p. 13a.) REASONS FOR DENYING THE WRIT I. SUMMARY OF ARGUMENT In the instant case, the Circuit Court, relying upon this Court’s decision in Robinson, supra, held that an eligibility requirement for health care benefits which was established through collective bargaining could not be set aside as being arbitrary or capricious unless its en- forcement violated federal law or policy. Petitioners would have this Court review the Circuit Court’s ruling on the basis (1) that the decision of this Court in Robinson should be narrowly construed and that the Circuit Court improperly extended its scope and intent; and (2) that the Circuit Court’s decision in this case is in conflict with decisions of other Courts of Ap- peals. Helen respectfully disagrees with both conten- tions. The decision and rationale of this Court in Robinson is applicable to any situation where the eligibility re- quirement under review, including its enforcement or administration, is established through the collective bar- T Reasons for Denying the Writ. gaining process. Thus, where, as here, the prior approval requirement is a product of collective bargaining, the action of the plan administrator or trustees in enforcing that requirement is not subject to review under a general reasonableness standard and should not be set aside un- less its enforcement would violate federal law or policy. The decision of the Circuit Court in this case is com- pletely consistent with the decisions of other Courts of Appeals. In those situations where trustees’ actions have been subject to review under a reasonableness standard, the involved regulation was unilaterally established by trustees or plan administrators, rather than through the collective bargaining process. This critical distinction was established by this Court in Robinson and has been recognized and followed by the Circuit Court in this case and by the Courts of Appeals in the cases cited by petitioners. In short, no basis exists for review by this Court of the Circuit Court’s decision. * II. Enforcement of collectively-bargained provi- sions in a health or pension plan is not subject to review on a standard of reasonableness. In Robinson, this Court held that where an eligibility requ:rement regarding health benefits was derived from collective bargaining, it should not be disturbed or set aside by a court in the absence of a finding that the requirement violated federal law or policy. 455 U.S. at 575. The collective bargaining provision in the 1974 Wage Agreement challenged in Robinson had provided different levels of health benefits for two classes of wid- ows of coal miners. Reasons for Denying the Writ. The United States Court of Appeals for the District of Columbia had held that the provision was arbitrary and violated Section 302(c)(5) of the LMRA, 29 U.S.C. § 186(c)(5). 640 F.2d 416 (D.C. Cir. 1981). However, this Court reversed the Court of Appeals, holding that provi- sions relating to the receipt of health benefits set forth in a collective bargaining agreement are not sub ect to re- view under a reasonableness standard and can only be challenged if they violate federal law or policy. 455 U.S. at 574-75. In so holding in Robinson, this Court expressly dis- tinguished a group of cases which had applied a reason- ableness standard in reviewing Fund eligibility require- ments and benefit levels. However, this Court observed that the aforementioned cases involved situations “in which trustees of employee benefit trust funds, not the collective-bargaining agreement, fixed the eligibility rules and benefit levels.” 455 U.S. at 573. As this Court further observed, the Trustees in Robinson, like the Trustees in this case, had not been “given ‘full authority’ to determine eligibility requirements and benefit levels ...” Id. Instead, the eligibility requirements and benefit levels had been “fixed by the 1974 collective-bargaining agreement” and the Trustees were “obligated to enforce” those determinations. 455 U.S. at 573-74. The same situation is presented in this case. The Benefit Plan established by the 1981 Wage Agreement provided that three requirements had to be satisfied be- fore a beneficiary such as petitioner Zayac became eligi- ble for health benefits for certain surgical procedures. One of the requirements, viz., prior approval by the plan administrator, had admittedly not been satisfied in this Reasons for Denying the Writ. case. Accordingly, Helen and its Plan Administrator de- clined to pay for the surgical procedure and the Trustees, as they were “obligated” to do, enforced the negotiated requirement and upheld Helen’s denial of benefits. The Circuit Court, consistent with this Court’s decision in Robinson, held that the Trustees’ action could not be set aside by a court unless enforcement would violate federal law or policy (App. A, p. 11a). 1. ROBINSON SHOULD NOT BE NARROWLY CONSTRUED. In an effort to create a conflict between the Circuit Court’s decision in this case and other Courts of Appeals’ decisions, petitioners attempt to construe Robinson nar- rowly. To begin with, petitioners contend that Robinson does not apply where a party does not seek to invalidate an eligibility rule. In a similar vein, petitioners argue that Robinson does not preclude a court from reviewing the decisions and actions of trustees in “administering” collectively-bargained eligibility requirements. Although Robinson factually involved a challenge to a benefit provision, as contrasted with the administration or enforcement of a benefit provision by trustees, there is simply no indication in this Court’s opinion that the holding in Robinson was intended to be limited to situa- tions where a party seeks to invalidate an eligibility requirement. To the contrary, as the Circuit Court ob- served in this case, this Court in Robinson appeared to have contemplated a situation where the plan was being administered by trustees, stating as follows: ‘Absent conflict with federal law, then, the trustees breached no fiduciary duties in administering the 1950 Benefit Trust in accordance with the terms 10 ier — Reasons for Denying the Writ. established in the 1974 collective-bargaining agree- ment.’ 455 U.S. at 574, 102 S.Ct. at 1233. (App. A, p. lla, emphasis added.) It is submitted that the Circuit Court properly inter- preted this Court’s holding in Robinson as precluding review, under a general reasonableness standard, of chal- lenges to the administration or the enforcement of collectively-bargained eligibility requirements. The sig- nificance of the Robinson decision lies in the fact that the eligibility requirement in question was not established by the trustees in the exercise of their discretionary author- ity but was, instead, fixed by collective bargaining. Thus, regardless of whether the case involves a challenge to a regulation itself or to its enforcement or administration by trustees, the rationale of Robinson applies equally to both situations so long as it involves, as here, a collectively-bargained regulation. In each case, the trustees are obligated to enforce the collectively- bargained regulation and the courts cannot invalidate the trustees’ action or modify the regulation unless it violates federal law or policy. Petitioners cite the case of Moore v. Reynolds Metals Co. Retirement Program, 740 F.2d 454 (6th Cir. 1984), in support of their restrictive interpretation of Robinson. In Moore, the Sixth Circuit found the logic of Robinson persuasive in a situation where the eligibility provision in the pension plan was not established in a collective bargaining agreement but was created unilaterally by the employer in response to ERISA requirements. Petitioners point to the Moore Court’s comments distinguishing the case of Sellers v O’Connell, 701 F.2d 575 (6th Cir. 1983). It is true that Sellers did indicate that 11 Reasons for Denying the Writ. a court may review the administration of a pension plan to determine whether the provisions are applied in an arbitrary or a capricious manner. Id. at 577. However, as the Moore Court pointed out, although the pension plan in Sellers was established pursuant to a collective bar- gaining agreement, the fund’s trustees had passed a reso- lution which was not a part of the collective bargaining agreement. Thus, as was observed in Moore, the Sellers Court was simply permitting review of a trustee-adopted resolution to determine whether it was arbitrary or ca- pricious. Moore, 740 F.2d at 456, n. 4 The decisions in Moore and Sellers are, therefore, completely consistent with the Circuit Court’s decision in this case. The prior approval eligibility requirement involved herein was established not by the Trustees but by the negotiators during collective bargaining. Conse- quently, the requirement is not subject to review under a _ reasonabieness standard. Alternatively, even if the deci- sion was subject to review under a reasonableness stan- dard, the action of the Trustees was not arbitrary or capricious unless it violated federal law or policy. Petitioners also point to language in the Moore case which indicates that courts may review trustees’ deci- sions in administering or interpreting a pension plan once the plan is established. It is apparent from the cases cited by the Moore Court that it was referring to situa- tions in which trustees had been called upon to admin- ister a plan and to interpret ambiguous plan provisions regarding pension eligibility, 740 F.2d at 457. This is to be contrasted with trustees’ action, as here, and in Robinson, in enforcing unambiguous health plan provi- 12 Pe, ~~ Reasons for Denying the Writ. sions which were established in the process of collective bargaining. 2. PETITIONERS ARE REALLY CHALLENGING THE ELI- GIBILITY REQUIREMENT ITSELF. Even if Robinson could be interpreted as only pre- cluding review of chailenges to eligibility requirements themselves, as contrasted with the administration or en- forcement of those requirements, it is apparent that the District Court (as do petitioners herein) really chal- ienged the requirement itself. In that regard, the Circuit Court observed as follows in this case: ...[I]t is apparent that the district court under- took te examine the reasonableness of the prior ap- proval requirement. Although its decision is couched in terms of the absence of ‘rational justification’ for ‘the trustees’ interpretation,’ the court was, in effect striking a particular eligibility requirement as itself unreasonable, since the trustees were applying the express requirement for eligibility that was written into the plan. (App. A, p. 12a.) Petitioners continue to contend that they are only seeking to have the prior approval requirement held to be “unjust [or unreasonable] under the facts of this case ...”” (Petition at 9.) However, the collectively-bargained prior approval requirement was unqualified. If the negotiators had desired to waive the requirement in situations where the claimant could subsequently estab- lish that he had met all of the other requirements, they could have done so. However, they did not and any at- tempt by the Trustees or a court to apply the prior ap- 13 Reasons for Denying the Writ. proval requirement in such a manner would constitute an improper modification of “the substantive terms of a collective-bargaining contract.” Robinson, 455 U.S. at 576. 3. THE PRIOR APPROVAL REQUIREMENT WAS THE RE- SULT OF COLLECTIVE BARGAINING. Petitioners also attempt to distinguish the instant case from Robinson on the basis that the prior approval requirement involved herein “is grounded in a discre- tionary determination of the Trustees and not a collec- tively bargained provision.” (Petition at 10.) More specif- ically, petitioners point to the fact that during the negotiation of the 1978 Wage Agreement, negotiators for BCOA and the UMWA adopted as a part of the employee benefit plans certain interpretations that had been uti- lized and established by the Trustees prior to 1978, in- _ cluding the prior approval requirement for certain surgi- cal procedures. The origin of the prior approval rule is insignificant. The critical fact is that it was discussed and adopted during and as a result of collective bargaining between the UMWA and BCOA, and became a part of the em- ployee benefit plan that was first established in the 1978 Wage Agreement and then carried forward in the 1981 Wage Agreement. The Trustees were not given the dis- cretionary authority to determine the eligibility require- ments or to modify their terms, except in limited situa- tions not applicable herein (App. A, p. 5-6a). In the latter regard, it should be noted that the contract provision challenged in Robinson also appears to have had its ori- gin in resolutions previously adopted by the Trustees. 455 U.S. at 423-24. 14 Reasons for Denying the Writ. 4. CLAIMANTS’ PROTECTION LIES IN THE COLLECTIVE BARGAINING PROCESS. Petitioners also argue in their petition that the effect of the Circuit Court’s decision in this case is to eliminate any protection that claimants have from allegedly arbi- trary and capricious “interpretation of a plan require- ment.” (Petition at 14.) Initially, it should be noted that little if any interpretation was needed by either the Plan Administrator or the Trustees to determine whether or not petitioners Zayac had obtained “prior approval” in this case. Moreover, it is submitted that the protection that claimants enjoy lies in the collective bargaining process and in their ability to obtain changes in the collectively-bargained requirements for health benefits in succeeding contracts. It is no more or less than the protection afforded signatory employers with respect to provisions in a collective bargaining agreement which they come to perceive as undesirable during the term of an agreement. III. The Circuit Court’s decision in this case is not in conflict with the decisions of other Courts of Ap- peals. Petitioners argue that the decision of the Circuit Court in this case is in direct conflict with decisions of other Courts of Appeals. Helen respectfully disagrees. In each of the cases cited by petitioners, the disputed plan provision had been established or formalized by trustees and had not been established in collective bargaining. This distinction is critical and was the basis of this Court’s decision in Robinson and the Circuit Court’s de- cision in the instant case. 15 Conclusion. CONCLUSION For these reasons, the petition for certiorari should be denied. November 1, 1985 Respectfully submitted, ANTHONY J. POLITO Counsel of Record RONALD S. CUSANO CORCORAN, HARDESTY, WHYTE & Pourro, P.C. Suite 210, Two Chatham Center Pittsburgh, Pennsylvania 15219 (412) 391-2740 Counsel for Respondent The Helen Mining Company 16 --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385018_0847%3A2. Public record. Not legal advice.